Privacy Policy

This Privacy Policy is part of and incorporated by reference into the
Terms of Service (the “Terms”) governing the use of all “LAKE” branded
software applications (the “Application/s”), which may operate on any
type of computing device (including without limitation, a mobile
device), and applies to your use of the Applications
and/or http://www.lakecoloring.com,
and/or URL which may replace it or which may be added to the list of
websites published by us and linking to this Privacy Policy (the
“Website/s”).

By agreeing to the Terms and/or using the Websites or the Applications,
you particularly agree to the collection, use and disclosure of your
information (including personal information) in accordance with this
Privacy Policy. We may collect and/or you may be asked to provide us
with your information (including personal information) any time you are
in contact with us or use the Applications or the Websites.

We take the privacy of our users and data security very seriously and
believe in the right of our users to know which data is collected and
for what purpose. We therefore strive to make our actions transparent
and allow our users to control the collected data and remove it if they
so wish, and we take all reasonable precautions to prevent unauthorised
access to this data.

We value your privacy and will never sell your information to anyone
without your knowledge and consent.

When accessing to our website and using any of our services you consent
to the collection, transfer, manipulation, storage, disclosure and other
uses of your information as described in this Privacy Policy.
Irrespective of which country you are based in, you authorize Lake to
use your information in, and as a result to transfer it to and store it
in Slovenia and any other country where Lake, or any third party service
providers acting on its behalf, operates. Privacy and data protection
laws in some of these countries may vary from the laws in the country
where you are based, but we will always take appropriate steps to
safeguard the privacy of your personal information.

Only when the transfer is based on one of the following safeguards, we
will transfer your personal information:

If a country outside of EEA ensures an adequate level of protection
in accordance with EEA data protection legislation.

If we have entered into standard contractual clauses with our
contractual partner that are adopted by Commission of European Union
in accordance with EEA data protection legislation and are deemed to
offer sufficient safeguards with respect to the protection of the
privacy rights.

Please read this Privacy Policy in order to learn more about the data we
collect, what do we use it for and how we protect your privacy.

Collected information

We may collect any or all of the information that you give us together
with data about your use of the website and applications, but we will
primarily use the collected data to provide you with a satisfactory
service and enhance your Lake experience.

We use information for (i) delivering and improving our services and
products, providing updates, technical troubleshooting, understanding
and analyzing trends in connection with usage of the apps, and
administering the apps; (ii) analytics and research in a way that we use
your information for understanding and analyzing trends in connection
with usage of the apps, gathering demographic information about user
base, data about where download of our app was performed, and we might
use created reports and analysis for the purpose of business
intelligence; (iii) security in a way to use your data for enhancing the
safety and security of our products and services; (iv)providing customer
support to you and to respond to your inquiries; and (v) our legal
obligation when we are required to do so by law.

Collection of device and technical information

We might collect the data necessary for you to use our app and for us to
maintain and analyze the functioning of the app and to personalize the
content of the app.

Collection of classical personal information

We may also collect personally identifiable information about you (such
as your name and surname, email address), as well as non-personally
identifiable information (such as age range and gender) that you provide
us by using our Applications or contact us directly via email.

We will only use the contact information you provide to us (for example,
your name and email address) for the purpose for which you provided it
to us. We will not share this data with third parties.

If you wish to delete your contact information that we received upon
your specific email inquiry, please send an e-mail to
info\@lakecoloring.com and your e-mail will be deleted from our
database.

What is collected data used for

In general

We use the information collected from you for delivering and promoting
our services, internal analysis and research to improve the services.
You hereby allow us to collect, process and store the data as stated in
this Privacy Policy. We use the information we collect about you/your
computing device to deliver services to you and to operate our business.

Delivering our services: developing, delivering and improving our
products, services, and content, tailoring our products and
services, providing software updates and product support,
understanding and analyzing trends in connection with usage of the
Applications and the Websites, administering the Applications and
the Websites, and customer communications. For information that can
be treated as personal information in some legislation, we use only
device identifiers.

Analytics and research: Understanding and analyzing trends in
connection with the usage of the Applications and the Website,
auditing, learning about user behavior within the Applications and
the Websites (how often you use the Application/Website, the events
that occur within the Application/Website, aggregated usage,
performance data etc.), gathering demographic information about our
user base, data about where the Application was downloaded from. For
information that can be treated as personal information in some
legislation, we use only device identifiers. We use the data we
receive from Third Party Social Network for internal analytics.

For a detailed explanation about what information is being used for what
purposes and by which Partners please see the “Cookie” section of this
Privacy Policy.

We cannot provide all services necessary for the successful operation of
our products by ourselves. We must therefore share collected information
with third parties (collectively referred to as “Partners”). We share
information that can be used to personally identify your device (e.g.
persistent identifiers such as IDFA, IDFV, advertising ID and IP
address) for the purposes of developing and delivering our services and
conducting analysis and research. We also reserve the right to disclose
your information (including personally identifiable information) when we
are legally required to do so, to disclose your information in an
anonymous and aggregated manner, meaning you could not be personally
identified from it.

Push notifications

We will only use push notifications to remind you about your activities
within the Application. You will receive push notifications only if you
are subscribed to push notifications in the Application. You can
unsubscribe in accordance with instruction provided for your device. We
collect push notification tokens in order for us to be able to determine
whether you are subscribed to push notifications. When you decide to
unsubscribe from push notifications, such push notification tokens will
be deleted from our database. You can do that by opening “Settings” menu
and tapping “Notifications”, find our app, tap on the icon of our app,
manage the “Notification” option by sliding it OFF or ON.

Third Party Social network connections

Users may choose to connect with third party social network connections
for posting, if they do so, they will have those connections saved in
Lake. By logging in to the Application using Third Party Social Network
or by using the Application to share content on such Third Party Social
Network, you are authorizing us to collect, store, and use any and all
information, in accordance with this Privacy Policy, that you agreed
that such third parties could provide to us through the Application
Programming Interfaces (“API”).

Your agreement takes place when you “accept” or “allow” (or similar
terms) one of our applications on such Third Party Social Networks. The
information you allow us to access varies by Application, and it is
affected by the privacy settings you and your friends establish on those
Third Party Social Networks. You can control and find out more about
these settings at Facebook and Game Center. Please bear in mind that
while using such third party offerings, you are using products or
services developed and administered by people or entities not affiliated
with or controlled by us. We cannot control the actions of those people
or entities, their content, their products and services and the use of
information you provide to them.

We access your social network profile if you allow us to for the
purposes of using in-app features.

These third party sites are governed by their own privacy policies and
end user agreements and we are not responsible for, and have no control
over, the sharing practices or policies of the third parties that
operate those sites.

We may access and store some or all of the following information, as
allowed by you, Third Party Social Networks and your preferences: (i)
your basic information from your profile, such as your name, surname,
email address, login ID, player identifier string; (ii) your photos and
videos. The Application may further ask you to allow us to (i) post on
such Third Party Social Networks on your behalf (e.g. photos, e-cards,
videos and status updates) and to (ii) manage your notifications (access
your notifications and mark them as read). Please keep in mind that we
will only do that if specifically directed by you and we will store ID
and your full name for the purposes of user identification. Other
information will be merely stored within the Application on your device
so that the Application will be able to communicate with Third Party
Social Network directly.

If you use Third Party Social Networks to participate in app related
activities, including but not limited to participation in downloading
and uploading of content, Lake may also collect, use, store, transmit
and publicly display statistical data regarding app. Data that
personally identifies you is collected, used, stored and transmitted in
accordance with this Privacy Policy.

Consent to public display of data upon your acceptance

We may publicly display your data when you participate in app related
activities for the purposes of user identification.

Storing of information

**We store your information for as long as needed to provide you with
our services and for as long as we are legally obliged to do so. We may
store information longer, but only in a way that it cannot be tracked
back to you. We delete the information as soon as we do not need them
for providing our services and in any event no later than five (5) years
after your interaction with our products has ceased. **

For EU Countries

We store personal information as long as it is needed for the provision
of our services. Traffic information is erased or made anonymous when it
is no longer needed for the purpose of the transmission or, in the case
of payable services, up to the end of the period during which the bill
may lawfully be challenged or payment pursued. Location information is
stored to the extent and for the duration necessary for the provision of
a value-added service. Cookies, direct marketing and provision of
value-added services information (including traffic information used for
these purposes) is stored as long as the same is necessary for the
provision of these activities, or up to the time when a user opts out
from such use in accordance with this Privacy Policy and the “Access to
Personal Information” section herein. Other information is stored for as
long as we consider it to be necessary for the provision of our
services. This section shall not prevent any technical storage or access
to information for the sole purpose of carrying out the transmission of
a communication or as strictly necessary in order for us to provide the
service you requested.

For US

We will retain collected information for the period necessary to fulfil
the purposes outlined in this Privacy Policy unless a longer retention
period is required or permitted by applicable legislation.

Storing might be different depending on the territory of collecting the
information and the applicable legislation, but we always strive to
store the information only as long as it is needed for the purposes of
providing, improving or personalizing our services.

Deletion of information

When information is no longer needed, we shall delete it using
reasonable measures to protect the information from unauthorized access
or use.

Protection of personal information

We have implemented: reasonable security measures to protect the
confidentiality, security and integrity of the collected information,
and to prevent unauthorized access and the use of information contrary
to this Privacy Policy. Although we use commercially reasonable efforts
to assure that your information remains secure when maintained by us,
please be aware that no security measures are perfect or impenetrable.

Integrity of personal information

We strive to enable you to keep your information accurate, complete and
up to date. You can access, check and ensure the integrity of your
information as described below.

Information collection relating to children

We do not knowingly collect personal information from, children under
13. If we learn that we have collected personal information of a child
under 13, we will take all reasonable steps to delete the information as
soon as possible. If you become aware that your child has provided us
with personal information without your consent, please contact us at
legal@lakecoloring.com.

In-app purchases

Use of our App is free of charge, however they might include in-app
purchases. In-app purchases may be made only upon entering the app store
password and you are responsible for maintaining the security of such
password. You should be aware of the 20-minute window after the
downloading of an Application, during which in-app purchases may be made
without inserting an in-app store password. You should also take into
account that some operating systems on mobile phones do not require
entering of the app store account password to carry out in-app
purchases.

Opt-out

You are always free to opt out from the future collection of your
personal information by LAKE in accordance with this Privacy Policy by
uninstalling all the Applications from each of your computing devices
and discontinuing use of the Websites.

Cookies

A cookie is a piece of data stored on the user’s computer tied to
information about the user. ​Most browsers allow you to disable cookies
or set your browser to alert you when cookies are being sent to your
computer. Please note that removing or blocking cookies may affect your
user experience and you may have to manually adjust some preferences
every time you visit our website and some functionalities may not work.

When you visit our website, you agree that we may place cookies to your
computer that uniquely identify your browser. We use cookies for very
limited purposes, that is to improve the quality of our service by
storing user preferences and other customization functions and to track
usage information. ​Cookies also enable us to provide you a personalized
experience, which is in line with your settings.

We use the following cookies:

Cookie name

Description

Expiration time

_ga

Used to distinguish users.

2 years

_gat

Used to throttle request rate.

10 minutes

Social network cookies

If you are a user of various social networks you very likely already
have cookies provid​ed by those social networks on your computer. As we
use the Like / Tweet/ +1 buttons on our title page those social networks
are able to detect your presence on lakecoloring.com using their cookie
already stored on your computer. These cases are covered by the privacy
policies of the social networks that you use.

Google Analytics cookie

As a great number of internet sites, we use Google analytics to measure
the usage of our website. Google Analytics uses a cookie to more
efficiently track individual users of the site.

Analytics

Google Analytics

Lake utilizes Google Analytics, a web analytics tool, that helps Lake
understand how users engage with our Site, so that we can review and
improve our Services. Google Analytics collects information anonymously.
It provides a report to Lake with website trends without identifying
individual visitors. Site usage is tracked using Google Analytics in
accordance with ​their Privacy Policy​. However, if you do not want your
data to be used by Google Analytics, you may opt-out by installing
​Google Analytics Opt-out Browser Add­on​.

Do Not Track

“Do Not Track” is a feature enabled on some browsers that sends a signal
to request that a web application disable its tracking or cross-site
user tracking. We do not do any cross-site user tracking for advertising
purposes, we only use cookies for analytical/sharing/authentication
purposes mentioned above. We are however legally obliged to disclose
that: “At present, Lake does not respond to or alter its practices when
a Do Not Track signal is received.”

Third Parties terms of service

We may provide links and/or connections to third-party websites or
services from our website and our mobile applications. We are not
responsible for the practices employed by websites or services linked to
or from Lake website or applications, including the information or
content contained therein.

Please remember that when you use a link to go from the Lake website or
applications to another website or service, our Privacy Policy does not
apply to third-party websites or services. Your browsing and interaction
on any third-party website or service, including those linked on our
website or in our applications, are subject to that third party’s own
rules and policies. We are not responsible for the privacy practices or
content of these third-party sites.

Legal basis for processing personal information

In each case where we process your information, we do so lawfully in
accordance with one of the legal bases set out.

Our legal basis for collecting and using the personal information will
depend on the personal information concerned and the specific context in
which we collect it. However, we will normally collect personal
information from you only where: (i) we have your consent to do so, (ii)
where we need the personal information to perform a contract with you
(e.g. to deliver a service you have requested), or (iii) where the
processing is in our legitimate interests (and not overridden by your
data protection interests or fundamental rights and freedoms). In some
cases, we may also have a legal obligation to collect personal
information from you, or may otherwise need the personal information to
protect your vital interests or those of another person.

Support

If you have further questions or any concerns regarding privacy with
Lake and have already signed up in Lake, the best way to get the answers
is to contact us by email at ​​support\@lakecoloring.com​.

If you submit a support request, we may receive your email address and
other information you provide related to your support request (“Support
Information”). We use Support Information only to provide support to
you. We don’t rent, sell or share your email address unless we have your
express consent and in the following circumstances:

We may share your Support Information with our support providers,
but only for the purpose of providing support to you.

We may share your email address and Support Information to enforce
compliance with our mobile application license agreements and user
agreements, to respond to legal requirements, when legally required
to do so, and at the request of governmental authorities.

We may share your email address and Support Information with a
successor entity or in connection with a corporate merger,
consolidation, sale of assets or other corporate reorganization
provided that use of your email address is otherwise in compliance
with this Privacy Policy.

YOUR DATA PROTECTION RIGHTS

You have numerous rights in connection with your personal information
and how we handle it, i.e to access, correct, update or request
deletion, object the processing, restrict processing, request
portability, withdraw your consent and right to file a complaint.

1. To access, correct, update or request deletion of your personal
information. You may do so by contacting us at legal@lakecoloring.com

2. To object to the processing of your personal information ask us
to restrict processing of your personal information or request
portability of your personal information. You may do so by contacting
us at legal@lakecoloring.com

3. If we are processing your personal information with your consent, you
can withdraw your consent at any time. Withdrawing your consent will
not affect the lawfulness of any processing we conducted prior to your
withdrawal, nor will it affect the processing of your personal
information conducted pursuant to lawful processing grounds other than
consent. You may do so by contacting us using the details at
legal@lakecoloring.com.

4. You have the right to file a complaint with a data protection
authority about our collection and use of your personal information.
For more information, please contact your local data protection
authority.

You can control and limit the type of personal information we collect
and process about you in a number of ways. For example, you can
disconnect your social media account(s) from our games or control your
social media privacy settings to limit the information shared with us.
You can also reset your mobile advertising identifier or limit ad
tracking altogether using the settings on your phone. You can also limit
or disable the use of cookies (or similar technologies).

We will respond to all requests we receive from individuals wishing to
exercise their data protection rights in accordance with applicable data
protection laws.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Any changes will be
placed here and the amended version will supersede this version of our
Privacy Policy. Use of information we collect is subject to the Privacy
Policy in effect at the time such information is collected. We will take
reasonable steps to draw your attention to any changes in our Privacy
Policy. However, to be on the safe side, we suggest that you read this
document each time you use the website to ensure that it still meets
with your approval.

If we make changes in the way we use your email address, we will notify
you in advance of posting by email. Such modifications will become
effective on the date set forth in the email.